This refers to the NRC inspection conducted on January 6-7 and 21, 1997,
at several of your facilities in Rockville, Maryland, for which an exit
meeting was held with you and members of your staff on February 6, 1997.
The inspection was conducted to determine whether activities authorized
by the license were conducted safely and in accordance with NRC requirements.
During the inspection, seven apparent violations of NRC requirements were
identified, as described in the NRC inspection report transmitted with
our letter, dated February 21, 1997. In the February 21, 1997 letter,
the NRC provided you an opportunity to either respond in writing to the
apparent violations addressed in the inspection report or request a predecisional
enforcement conference. You responded to the apparent violations, in a
letter to the NRC, dated March 12, 1997.

Based on the information developed during the inspection and the information
you provided in your March 12, 1997 response, the NRC has determined that
violations of NRC requirements occurred. The violations are cited in the
enclosed Notice of Violation (Notice) and the circumstances surrounding
them are described in detail in the subject inspection report. The violations
involve (1) failure of the Radiation Safety Committee (RSC) to meet on
a scheduled basis at intervals not exceeding 3-months; (2) failure of
the Radiation Safety Officer (RSO) to conduct an annual audit of each
approved project; (3) failure to review the radiation protection program
content and implementation at least annually; (4) failure to conduct fixed
and removable contamination surveys at least once each month in laboratories
where radionuclides are used; (5) failure to provide one hour of annual
training to each individual working with radioactive material; (6) failure
to conduct a physical inventory every six months to account for all sealed
sources and devices containing licensed material; and (7) failure to label
each container of licensed material with the required caution label.

These violations indicate a significant lack of attention to licensed
activities by the RSO and the Radiation Safety Committee (RSC). In fact,
some of the violations that occurred were the direct responsibility of
the RSO or RSC. Management attention to the radiation safety program is
warranted to ensure that licensed activities are conducted safely and
in accordance with requirements. While the violations in question did
not have an impact on the health and safety of the public, or your staff,
such violations are potential precursors to more serious problems, and
therefore, it is important that the RSO and RSC actively look for, identify,
and correct such problems. At your facility, this did not occur. Therefore,
these violations have been classified in the aggregate as a Severity level
III problem in accordance with the "General Statement of Policy and
Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600,
at Severity Level III.

In accordance with the Enforcement Policy, a base civil penalty in the
amount of $2,750 is considered for a Severity Level III violation. Because
your facility has not been the subject of an escalated enforcement action
within the last two years, the NRC considered whether credit was warranted
for Corrective Action in accordance with the civil penalty assessment
process in Section VI.B.2 of the Enforcement Policy. Credit for corrective
actions is warranted because your corrective actions were both prompt
and comprehensive. These actions, which were described in your March 12,
1997 letter, and/or during the inspection, included, but were not limited
to: (1) scheduling the RSC meetings for the remainder of 1997; (2) conduct
of audits of all ten of your approved projects which were completed by
February 28, 1997; (3) conduct of a training session with staff on February
4, 1997, and February 20, 1997, with plans for annual training thereafter;
(4) plans to have the RSO provide a written report regarding inventory
findings during to the RSC during the second and fourth quarterly meetings;
and (5) appropriately labeling of containers that had not been labelled,
and covering the need for such labelling during the February 4, 1997 training
session.

Therefore, to encourage prompt and comprehensive correction of violations,
I have been authorized not to propose a civil penalty in this case. However,
similar violations in the future could result in further escalated enforcement
action.

The NRC has concluded that information regarding the reason for the violations,
the corrective actions taken and planned to correct the violations and
prevent recurrence, and the date when full compliance will be achieved,
are already adequately addressed on the docket in your March 12, 1996
letter. Therefore, you are not required to respond to this letter unless
the description therein does not accurately reflect your corrective actions
or your position. In that case, or if you choose to provide additional
information, you should follow the instructions specified in the enclosed
Notice.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice,"
a copy of this letter, its enclosure, and any response, if you choose
to provide one, and your March 12, 1997 letter, will be placed in the
NRC Public Document Room (PDR).

Sincerely,
ORIGINAL SIGNED BY
WILLIAM L. AXELSON for
Hubert J. Miller
Regional Administrator

During an NRC inspection conducted on January 6-7 and 21, 1997, at various
of your facilities in Rockville, Maryland, for which an exit meeting was
held on February 6, 1997, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure
for NRC Enforcement Actions," (Enforcement Policy) NUREG-1600, the
violations are listed below:

A. Condition 22 of License No. 19-07538-01 requires that licensed
material be possessed and used in accordance with the statements, representations,
and procedures contained in a letter, dated November 2, 1994.

Enclosure 1 of the November 2, 1994 letter states that the radiation
safety committee shall meet on a scheduled basis not exceeding 3-month
intervals.

Contrary to the above, the radiation safety committee did not meet
on a scheduled basis not exceeding 3-month intervals. Specifically,
during calendar year 1996, the radiation safety committee did not
meet between March 29 and October 2, an interval exceeding 3 months.
(01013)

Item 5.b on page 2 of the November 2, 1994 letter states that an
audit of each approved project and the individuals working on that
project will be conducted annually by the RSO or his designee. The
audit will include, but not be limited to: inventory records, user
survey records, evaluation of training needs, independent work area
surveys, and authorization terms compliance.

Contrary to the above, in 1995 and 1996, the RSO did not conduct
an audit of each approved project, and the individuals working on
that project. (01023)

Enclosure 7 of the November 2, 1994 letter states that each laboratory
should be surveyed for fixed and removable contamination at least
once each month in which radionuclides are used by the radiation users
in that laboratory.

Contrary to the above, on several occasions in 1995 and 1996, surveys
for fixed and removable contamination were not performed at least
once each month for certain laboratories in which radionuclides
were used by the radiation users. Specifically, radionuclides were
used at the 12709 Twinbrook facility in Room 23 in September, October,
and December 1996; in Room 37 in November 1996; and in Room 4C in
March, July, September, November 1995 and February 1996 and contamination
wipe surveys were not performed during those months. (01033)

Enclosure 3 of the November 2, 1994 letter, Item 2.b, states that
each individual working with radioactive materials is expected to
receive at least one hour of continuing education each year. This
may be met through attending short courses, seminars, briefings or
topical presentations, on subjects relevant to radiation safety, given
by the RSO or other individuals knowledgeable in radiation safety.

Contrary to the above, in 1995 and 1996, individuals working with radioactive
material did not receive at least one hour of continuing education.
Specifically, short courses, seminars, briefings or topical presentations,
on subjects relevant to radiation safety, were not given by the RSO
or other individuals knowledgeable in radiation safety in 1995 and 1996.
(01043)

Contrary to the above, as of January 21, 1997, the licensee did not
review the radiation protection program content and implementation at
least annually. Specifically, a review of the radiation protection program
content and implementation for 1995 had not been completed at the time
of the inspection. (01053)

C. Condition 15 of License No. 19-07538-01 requires that the licensee
conduct a physical inventory every six months to account for all sealed
sources and devices containing licensed material received and possessed
under the license.

Contrary to the above, in 1995 and 1996, physical inventories were
not conducted to account for all sealed sources and devices containing
licensed material. (01063)

D. 10 CFR 20.1904(a) requires the licensee to ensure that each container
of licensed material bears a durable, clearly visible label bearing
the words "CAUTION, RADIOACTIVE MATERIAL," or "DANGER,
RADIOACTIVE MATERIAL." The label must also provide sufficient information
(such as the radionuclide(s) present, an estimate of the quantity of
radioactivity, the date for which the activity is estimated, etc.) to
permit individuals handling or using the containers, or working in the
vicinity of the containers, to take precautions to avoid or minimize
exposures.

Contrary to the above, as of January 21, 1997, six containers of liquid
licensed material stored in the radioactive waste storage area did not
bear labels that identified the radionuclides or the quantity of radioactivity,
and an additional container of liquid waste did not identify the radionuclide,
nor did these containers otherwise bear sufficient information to permit
individuals handling or using the container, or working in the vicinity
of the containers, to take precautions to avoid or minimize exposure.
(01073)

These violations are classified in the aggregate as a Severity Level
III problem. (Supplements IV and VI)

The NRC has concluded that information regarding the reason for the violations,
the corrective actions taken and planned to correct the violations and
prevent recurrence, and the date when full compliance will be achieved,
are already adequately addressed on the docket in the licensee's March
12, 1997 letter in response to Inspection Report No. 30-04544/97-01. However,
you are required to submit a written statement or explanation pursuant
to 10 CFR 2.201 if the description therein does not accurately reflect
your corrective actions or your position. In that case, or if you choose
to respond, clearly mark your response as a "Reply to a Notice of
Violation," and send it to the U.S. Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the
Regional Administrator, Region 1, within 30 days of the date of the letter
transmitting this Notice of Violation (Notice).